From: Vaidyanathan, Kavita 

Sent: Friday, June 05, 2015 4:57 PM

To: Patty Plourde; Manufactured_Housing

Cc: Exparte Communications

Subject: RE: Regulations.gov - Proposed Rule Document manufactured

Dear Ms. Plourde,

In response to your phone call and e-mail below the proposed rule that you reference below 

regarding energy efficiency standards for manufactured housing has not been issued yet by the 

Department of Energy (DOE) and therefore we are still in the process of drafting a proposed rule 

and any necessary definitions. Most recently DOE determined that development of proposed 

manufactured housing energy conservation standards would benefit from a negotiated 

rulemaking process. On July 16, 2014, the manufactured housing working group was established 

under the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) in 

accordance with the Federal Advisory Committee Act and the Negotiated Rulemaking Act. The 

working group consisted of representatives of interested stakeholders with a directive to consult, 

as appropriate, with a range of external experts on technical issues in development of a term 

sheet with recommendations on the proposed rule. On October 31, 2014, the working group 

reached consensus on energy conservation standards in manufactured housing and assembled its 

recommendations for DOE into a term sheet that was presented to ASRAC. ASRAC approved 

the term sheet during an open meeting on December 1, 2014, and sent it to the Secretary of 

Energy to develop a proposed rule. DOE is in the process of developing a proposed rule.

The docket is available for review at www.regulations.gov and includes the working group term 

sheet recommendations, Federal Register notices, public comments, meeting transcript 

summaries, and other supporting documents and materials. All documents in the docket are 

listed in the regulations.gov index. However, not all documents listed in the index may be 

publicly available, such as information that is exempt from public disclosure. 

A link to the docket web page can be found 

at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=97.

In addition, we consider this exchange of correspondence an ex parte communication. DOE will 

follow its policy for such communications. DOE guidance on ex parte communications was 

published on January 21, 2009 (74 FR 4685) and can be found 

at: http://energy.gov/gc/downloads/guidance-ex-parte-communications. As described in the 

guidance, communications between individuals or entities and DOE or its contractors during the 

rulemaking process will be included in the public docket consistent with the ex parte guidance.

Thank you,

Kavita

Kavita K. Vaidyanathan

Attorney-Adviser

Office of the General Counsel 

U.S. Department of Energy 
1000 Independence Ave S.W.

6B-159

Washington, DC 20585

Phone: 202-586-0669

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From: Patty Plourde [mailto:Patty@PattyPlourde.com] 

Sent: Friday, June 05, 2015 4:31 PM

To: Manufactured_Housing; Vaidyanathan, Kavita

Subject: Regulations.gov - Proposed Rule Document manufactured

Joe & Kavita,

Are you defining the different between pre-manufactered(factory built with permanent 

foundation) and manufactured (mobile home with HUD ID tag)?

When I read this its confusing to me, sometimes I think its discussing prefab, other 

times I think its discussing mobile home. The ability to differentiate can be 

confusing. HUD has a clear definition. It's important to get separation from these two 

tracks. Examples: Mobiles are not financeable with traditional methods, prefabs 

are. Mobiles devalue over time, pre-fabs do not. Building codes of prefab are 

consistent with traditional single family homes, mobiles are not. 

Respectfully,

Patty Plourde, Pres.

Real Estate Partners.MN

of: 952-946-1999

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